Copyright 2018 by Khaled A. Beydoun
Printed in U.S.A.
Vol. 112, No. 5
LONE WOLF TERRORISM: TYPES, STRIPES, AND
Khaled A. Beydoun
ABSTRACT—The recent spike in mass shootings, topped by the October 1,
2017, Las Vegas massacre, dubbed the “deadliest mass shooting in modern
U.S. history,” has brought newfound urgency and attention to lone wolf
violence and terrorism. Although a topic of pressing concern, the
phenomenon—which centers on mass violence inflicted by one individual—
is underexamined and undertheorized within legal literature. This scholarly
neglect facilitates flat understandings of the phenomenon and enables the
racial and religious double standards arising from law enforcement
investigations and prosecutions of white and Muslim lone wolves.
This Essay contributes a timely reconceptualization of the
phenomenon, coupled with a typology adopted from social science, for
understanding the myriad forms of lone wolf terrorism. In addition to
contributing the theoretical frameworks to further examine lone wolf
terrorism within legal scholarship, this Essay examines how the assignment
of the lone wolf designation by law enforcement functions as: (1) a
presumptive exemption from terrorism for white culprits and (2) a
presumptive connection to terrorism for Muslim culprits. This asymmetry is
rooted in the distinct racialization of white and Muslim identity, and it is
driven by War on Terror baselines that profile Muslim identity as
presumptive of a terror threat.
AUTHOR—Khaled A. Beydoun, Associate Professor of Law, University of
Detroit Mercy School of Law; Senior Affiliated Faculty, University of
California at Berkeley, Islamophobia Research & Documentation Project
This Essay was originally published in the Northwestern University Law Review Online on February
22, 2018. 112 NW. U. L. REV. ONLINE 177 (2018), https://scholarlycommons.law.northwestern.edu/cgi/
NORTHWESTERN UNIVERSITY LAW REVIEW
(IRDP); and author of American Islamophobia: Understanding the Roots
and Rise of Fear (University of California Press, 2018).
INTRODUCTION: A TALE OF TWO LONE WOLVES..................................................... 1214
A. Las Vegas Shooting—October 1, 2017................................................... 1214
B. The Orlando Nightclub Shooting—June 12, 2016 .................................. 1216
C. Two Lone Wolves, but Only One Terrorist ............................................. 1217
I. THEORIZING LONE WOLF TERRORISM ............................................................. 1219
A. Defining “Lone Wolf Terrorism” .......................................................... 1219
B. A Typology: Lone Wolves of Many Stripes ............................................. 1221
II. LONE WOLVES AND RADICALIZATION............................................................. 1226
A. Radicalization and Counter-Radicalization ........................................... 1227
B. Radicalization and Racialization........................................................... 1231
III. POLICING LONE WOLF TERRORISM ................................................................. 1236
A. Lone Wolf as a Terrorism Exemption .................................................... 1237
B. Lone Wolf as a Terrorism Connection ................................................... 1239
CONCLUSION ........................................................................................................ 1242
[A]t this point, we believe it is a local individual [not a terrorist], he
resides here locally.
—Clark County Sherriff Joseph Lombardo‡
As far as we can tell right now, this is certainly an example of the kind
of homegrown extremism that all of us have been so concerned about for
a very long time.
—President Barack Obama††
INTRODUCTION: A TALE OF TWO LONE WOLVES
A. Las Vegas Shooting—October 1, 2017
Stephen Paddock peered onto the concert hall across the boulevard from
the thirty-second floor of the Mandalay Bay Hotel.1 The illuminated Las
Tom Batchelor, Nevada State Law Defines Law Vegas Mass Shooting as an Act of Terrorism,
INDEPENDENT (Oct. 2, 2017, 10:27 AM), http://www.independent.co.uk/news/world/americas/las-vegasshooting-nevada-terrorism-state-law-act-police-stephen-paddock-a7978456.html
[https://perma.cc/X3PH-TGMC] (characterizing Stephen Paddock, the culprit of the Las Vegas shooting).
Julie Hirschfeld Davis, Obama Says Orlando Gunman Was Probably a Homegrown Extremist,
N.Y. TIMES (June 13, 2016), https://www.nytimes.com/2016/06/14/us/politics/obama-orlando-shooterisis.html [https://perma.cc/6MLL-PKPD] (characterizing Omar Mateen, the culprit of the Orlando
Jose A. Delreal & Jonah Engel Bromwich, Stephen Paddock, Las Vegas Suspect, Was a Gambler
Who Drew Little Attention, N.Y. TIMES (Oct. 2, 2017), https://www.nytimes.com/2017/10/02/us/stephenpaddock-vegas-shooter.html [https://perma.cc/R2DX-V5FT].
Lone Wolf Terrorism
Vegas Strip was a familiar sight for the sixty-four-year-old, who for years
walked on the very grounds he looked down upon minutes after 10:00 PM
that Sunday evening, October 1, 2017.2 Thousands of people gathered for the
country music festival across Las Vegas Boulevard, celebrating a musical
genre that Paddock counted among his favorites.3 One can imagine the scene:
inches from the suite’s panorama window, Paddock’s stare was fixed and his
stance frozen, high atop the city where he satisfied his zeal for gambling
huge sums of money within the Strip’s familiar string of hotels.4
However, that evening, Paddock would aim to gratify a different kind
of zeal. He stood feet away from his stockpile of twenty-three guns,5 which
he stealthily transported into his suite. Minutes later, he used those guns to
kill fifty-eight people and injure over 500 more attending the Route 91
Harvest festival concert.6 Paddock opened fire on the crowd of 22,000 at
10:05 PM and continued shooting for the next ten minutes—a time span that
probably seemed like an eternity for those below.7
The shooting was ultimately dubbed “the deadliest mass shooting in
modern U.S. history” by a number of media outlets.8 Consequently, the City
of Las Vegas and Paddock’s name will forever be associated with one of the
darkest moments in America’s recent memory. However, hours after the
attack, before an investigation commenced, the Clark County Sherriff
disassociated Paddock from terrorism by calling him a “lone wolf,” and the
media firestorm covering the tragedy followed suit.9
Amy O’Neill and Bob Ortega, The Unknowable Stephen Paddock and the Ultimate Mystery: Why?,
CNN (Oct. 7, 2017, 9:40 AM), http://www.cnn.com/2017/10/06/us/unknowable-stephen-paddock-andthe-mystery-motive/index.html [https://perma.cc/JP26-YGU4].
Barbara Liston et al., Las Vegas Gunman Stephen Paddock Was a High-Stakes Gambler Who ‘Kept
to Himself’ Before Massacre, WASH. POST (Oct. 2, 2017), https://www.washingtonpost.com/news/postnation/wp/2017/10/02/las-vegas-gunman-liked-to-gamble-listened-to-country-music-lived-quiet-retiredlife-before-massacre [https://perma.cc/DG4Y-8VSR].
Matt Pearce, David Montero & Richard Winton, Las Vegas Gunman Shot Security Guard a Full
Six Minutes Before Opening Fire on Concertgoers, Police Reveal, L.A. TIMES (Oct. 9, 2017, 6:10 PM),
See, e.g., Bill Chappell & Doreen McCallister, Las Vegas Shooting Update: At Least 59 People Are
Dead After Gunman Attacks Concert, NPR (Oct. 2, 2017, 3:15 AM), https://www.npr.org/sections/
Delreal & Bromwich, supra note 1.
NORTHWESTERN UNIVERSITY LAW REVIEW
B. The Orlando Nightclub Shooting—June 12, 2016
Before the Las Vegas massacre, the horrific shooting in Orlando on
June 12, 2016, held the designation of the “deadliest mass shooting” in U.S.
history.10 Shortly after midnight that Sunday morning, Omar Mateen opened
fire inside Pulse Nightclub, a nightlife hub and “safe space” for the
metropolitan Orlando area’s diverse LGBTQ communities.11 He killed fortynine people and injured fifty more12 during a night when 90% of the clubgoers were Latino.13
Like Paddock, Mateen, a “deeply disturbed”14 twenty-nine-year-old
American of Afghan heritage,15 took his own life shortly after opening fire.
But unlike Paddock, Mateen was Afghan and Muslim, identities that are
routinely conflated with—and inextricably tied to—terrorism.16 Because of
his faith and ethnicity, Mateen fit within the embedded profile of the terrorist,
and he was “raced” as such17—acting in a purely individual capacity would
not change that racial and religious equation. Law enforcement and many
voices within mainstream media labeled him a “lone wolf,” but the
“radicalized” variety: connected—not exempted—from terrorism.18
However, the Federal Bureau of Investigation (FBI) was well
acquainted with Mateen and previously cleared him from terror affiliation or
involvement on two occasions. FBI agents interviewed Mateen three times
during 2013 and 2014, delving deep into his personal life and assigning an
Maia Davis, Orlando Nightclub Mass Shooting Is Deadliest in US History, ABC NEWS (June 12,
2016, 4:06 PM), abcnews.go.com/US/orlando-nightclub-mass-shooting-deadliest-us-history/story?id=
39797486 [https://perma.cc/3VYW-U6TH] (“The 50 deaths, so far, are 18 more than . . . the second mostfatal massacre . . . according to data from Mother Jones that goes back to 1982.”).
Daniel D’Addario, Orlando Shooting: The Gay Bar as Safe Space Has Been Shattered, TIME (June
Hirschfeld Davis, supra note ††.
Steven W. Thrasher, Latino Community Mourns Pulse Shooting Victims: “90% Were Hispanic”,
GUARDIAN (June 14, 2016, 1:36 PM), https://www.theguardian.com/us-news/2016/jun/14/latinohispanic-orlando-shooting-victims [https://perma.cc/Q54J-DVP5].
See Mark Mazzetti et al., Omar Mateen, Twice Scrutinized by F.B.I., Shows Threat of Lone
Terrorists, N.Y. TIMES (June 13, 2016), https://www.nytimes.com/2016/06/14/us/politics/orlandoshooting-omar-mateen.html [https://perma.cc/AGN3-44E3].
Orlando Gay Nightclub Shooting: Who Was Omar Mateen?, BBC (June 14, 2016),
See Leti Volpp, The Citizen and the Terrorist, 49 UCLA L. REV. 1575, 1586 (2002) (stating that
“[v]ery few persons who appear ‘Middle Eastern, Arab, or Muslim’ are terrorists,” however, “[m]any
men who fall into this category, including law professors, have been subjected to questioning”).
See Natsu Taylor Saito, Symbolism Under Siege: Japanese American Redress and the “Racing”
of Arab Americans as “Terrorists,” 8 A SIAN L.J. 1, 12 (2001).
David K. Li, FBI Chief: Orlando Gunman Was Self-Radicalized Lone Wolf, N.Y. POST (June 13,
2016, 1:00 PM), https://nypost.com/2016/06/13/fbi-chief-orlando-gunman-had-strong-indications-ofradicalization [https://perma.cc/5Z77-WVHP].
Lone Wolf Terrorism
undercover agent to make contact.19 Ultimately, the FBI closed Mateen’s
case, finding that his “connections to terrorism were . . . insubstantial.”20
Despite these conclusions, and the lack of material evidence tying
Mateen’s murders to a transnational terror network or terrorist ideology,21
law enforcement and mainstream media outlets swiftly turned to the
presumption and narrative of terrorism.22 In a span of hours, law enforcement
had branded Mateen a terrorist before an investigation into his motives and
ties even commenced.
C. Two Lone Wolves, but Only One Terrorist
Two lone wolves, with no established or substantial ties to transnational
terror networks, were at the center of the tragic tales of the Las Vegas
massacre and the Orlando nightclub shooting. These two incidents, which
rank among the deadliest mass shootings in contemporary American history,
illustrate how terrorism is instantly presumed when the lone wolf killer is
Muslim, and the prospect of terrorism is typically dismissed when the actor
is white (and non-Muslim). Race and religion stand at the center of any tale
involving a lone wolf. More often than not, race and religion are the most
salient factors in determining whether law enforcement will conduct a
terrorism investigation and prosecution.
The recent list of shootings and mass killing involving white nonMuslim and Muslim culprits has revealed a pattern in which the former are
generally designated lone wolf killers, and the latter are presumptive lone
wolf terrorists—a critical distinction whereby killers are prosecuted
criminally outside of the counterterror process,23 while terrorists are
prosecuted on both grounds. While discursive understandings of lone wolf
conceive of the concept exclusively as an exemption from terrorism applied
to white culprits,24 the designation can be tied to terrorism, conventional
criminal investigations and charges, or both. This Essay argues that these
Mazzetti et al., supra note 14.
Spencer Ackerman, Orlando Gunman Known to FBI Shows Difficulty of “Lone Wolf” Cases,
GUARDIAN (June 12, 2016, 6:22 PM), https://www.theguardian.com/us-news/2016/jun/12/floridagunman-omar-mateen-fbi-lone-wolf [https://perma.cc/7B4U-FPDD].
Mazzetti et al., supra note 14.
JEFFREY CONNOR & CAROL ROLLIE FLYNN, REPORT: LONE WOLF TERRORISM, GEORGETOWN
UNIV. SEC. STUDIES PROGRAM: NAT’L SEC. CRITICAL ISSUE TASK FORCE 9 (2015) (“Absent political
motivation, an attack would more closely resemble traditional forms of crime, organized violence, or hate
See, e.g., Chuck Hobbs, “Lone Wolf” Characterization of Mass Murders Is the Epitome of White
Privilege, HILL (Oct. 3, 2017, 12:40 PM), http://thehill.com/opinion/criminal-justice/353627-lone-wolfcharacterization-of-murderers-is-the-epitome-of-white [https://perma.cc/3VGU-Y6SG].
NORTHWESTERN UNIVERSITY LAW REVIEW
investigations and charges often depend on the racial and religious identity
of the culprit.
Although both Paddock and Mateen were lone wolves—culprits
carrying out mass violence in an individual capacity—their distinct racial
and religious identities altered the legal effect of that designation.
Furthermore, race and religion steered whether their mass shootings were
pursued as acts of terror or merely criminal acts. This Essay investigates the
racial and religious dimensions of the lone wolf designation, beginning with
a comparative racial analysis of white and Muslim identity, and how deeply
rooted tropes assigned to both drive criminal and counterterror framing of
lone wolf culprits. After an examination of the racial roots of this disparate
framing, this Essay proceeds to examine how the lone wolf designation
deployed by law enforcement functions as a presumption of terror exemption
when the culprit is white (and non-Muslim), and as a presumption of terror
connection when the culprit is Muslim.
In addition to investigating the racial and religious double standards tied
to law enforcement, this Essay theorizes the meaning and distinct types of
lone wolf terrorism. Further, it contributes to legal literature a useful
typology that highlights lone wolf terrorism’s myriad forms. In addition to
illustrating that lone wolf terrorism is not a strategic or structural monolith,
this typology enables critical analysis of the phenomenon beyond the myopic
racial and religious frames that stifle the discourse.
While there is robust legal and interdisciplinary literature examining
modern terrorism, generally fixating on Muslim actors and networks,25
scarce attention has been specifically paid to lone wolf terrorism,26 a pressing
area of scholarly and practical concern. By theorizing lone wolf terrorism in
relation to prevailing counterterror programs, and introducing social science
frameworks that outline the various types of lone wolf actors, this Essay fills
this void. In addition, this Essay sheds light on the origins of a double
standard whereby law enforcement presumptively exempts white culprits
from terrorism, but connects Muslim culprits to terrorism, as evidenced by
an analysis of the two deadliest mass shootings in recent history.
Part I conceptualizes the meaning of lone wolf terrorism and offers a
theoretical framework that highlights its four distinct types. Part II situates
See, e.g., MARC SAGEMAN, UNDERSTANDING TERROR NETWORKS (2004) (examining terrorism
and exclusively concerned with Muslim terror networks, although the title and phrase “terror networks”
is religiously neutral; a highly influential book cited widely within legal scholarship).
One of the few law review articles that specifically examines lone wolf terrorism conflates the
phenomenon with Muslims, illustrating the scholarly fixation on Muslim terrorists and, relatedly, the
failure to theorize lone wolf terrorism as a phenomenon beyond a stereotypical frame. See Kendall Coffey,
The Lone Wolf—Solo Terrorism and the Challenge of Preventative Prosecution, 7 FLA. INT’L U. L. REV.
Lone Wolf Terrorism
law enforcement investigation and prosecution of lone wolves within the
Department of Homeland Security’s (DHS) primary counterterror program,
counter-radicalization policing, that practically frames radicalization as a
Muslim phenomenon. Part III analyzes the investigative and prosecutorial
presumptions assigned to lone wolf actors, which regularly impute
radicalization as the motive if the culprit is Muslim and dismiss the
possibility if the culprit is white.
THEORIZING LONE WOLF TERRORISM
Despite becoming an emerging staple of counterterror policing and
parlance, “lone wolf terrorism” has no consensus definition. This is due in
part to the competing and conflicting definitions of terrorism, which is
defined broadly by U.S. law enforcement and the military, and is theorized
even more broadly by scholars.27 The term’s application drives its
multivalence, often giving terrorism distinct legal meanings when assigned
to white, minority, or Muslim actors. Moreover, lone wolf terror attacks are
a relatively new phenomenon, “increasing from thirty attacks in the 1970s to
seventy-three in the 2000s, a growth of 143 percent.”28 Therefore, popular
and political uses of the term have outpaced scholarly framing of lone wolf
terrorism, and indeed, those uses have preceded formal conceptualization
that can guide lawmakers and law enforcement.
Assessing the meaning and types of lone wolf terrorism is the focus of
this Part. Section A offers several definitions, while Section B outlines a
typology for understanding lone wolf terrorism, an essential first step before
examining the presumptive double standards tied to the racial and religious
identity of the culprit.
A. Defining “Lone Wolf Terrorism”
Lone Wolf Terrorism, a 2015 report by the Georgetown University
Security Studies Program, provides a useful definition and framework for
understanding the phenomenon.29 It defines lone wolf terrorism as “the
deliberate creation and exploitation of fear through violence or threat of
violence committed by a single actor who pursues political change linked to
a formulated ideology, whether his own or that of a larger organization, and
who does not receive orders, direction, or material support from outside
See generally Cyrille Begorre-Bret, The Definition of Terrorism and the Challenge of Relativism,
27 CARDOZO L. REV. 1987 (2006) (providing a th ...
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